Professional Documents
Culture Documents
Plaintffi' Motion Appealing and to Overturn Discovery Master's Order No. I3,
Dated March 8, 2016, Dated March 16, 2016, Filed March 17, 2016, filed June 6,2016,
Plaintiffs' hereby resubmit Exhibit 38, which was previously filed under seal.
ALSTON
ERIC G. FERRER
GLENN T. MELCHINGER
SUSAN DORSEY
Attorneys for Plaintiffs
962660v1111047
-l
SOH 20
EXHIBIT "38"
s 7896
2
After that first caU I placed to Principal Dickerson in the middle of April, I
heard nothing more about the HSDB incident until Mavis Kawamura came
to my office again in the latter part of May, some six weeks after my first
conversation with Principal D ickerson. Ms. Kawamura told me that
Principal Dickerson had not entered any data regarding the HSDB incJdent
into the Department of Education's electronic data base. That upset and
alarmed me, because Principal Dickerson bad not complied with my April
directive to her to immediately follow Chapter 19 procedures, and I knew
that by law there was a small amount of time wi th in which that type of data
must be entered. There is no leeway in follow ing this rule.
I called Principal Dickerson immediately after Ms. Kawamura told me
this, and asked her if she had inputted the data into ECSSS, the DOE's
electronic database. She said "No." I told her to do it right away.
A day or two later, I called Principal Dickerson to confinn whether or not
she had entered the da ta. She to ld m e that she could not enter certain
information because she bad passed the fi ve-day dead line for doing so. f
took this to mean that because she had not recorded her report of the Apri l
141h arrest within the five-day w indow required by Chapter 19, the system
recognized that the deadline had passed. and would not a llow Principal
Dickerson's data to be entered. To me, Principal Dickerson had seriously
breached Department of Education protocol and regulations.
I did not hear again about the H SDB situation until July 12, 2011, when I
received a call from Honolulu Police Department detective Dwight Sato,
who requested a meeting with me. He came to the Honolulu District Office
the next morning with a female detective, Darien Thornley. They told me
about the April 14th incident on the bus, and then went on to describe how
they believed the suspect was the ringleader of a group of HSDB student
sexual predators. They estimated there were five suspects responsible for
sexual assaults invol ving possibly thirty-five victims. The detectives told
me that their investigation indicated t hat these assaults had gone on for
years, in a variety of locations on the HSDB campus, culminating with the
assault on the school bus. Detective Sato told me" I believe you have a
problem with supervision at the school."
After the detectives left, I conferred with my Personnel Specialist, Peter
Uehara, and we both con curred that Principal Dickerson be immediately
placed on Department Directed Leave.
SOH 21
s 7897
SOH 22
s 7898
4
Principal Dickerson in this matter, and the possible consequences of those
instances. I am extremely concerned that her misconduct goes back many
years. It is my hope that all previous incidents are addressed and resolved,
whether through the criminal process or administratively.
Finally, the record indicates Principal Dickerson took n~ne of the
required documented action under Chapter 19 until May 31, 2011, a full six
weeks after the April 14, 2011 incident. This alanning inaction is reflected
in ECSSS documents, which also reveal that the required data input on the
applicable case forms are incomplete, and therefore inv.alid. Those
incomplete forms include the Confidential Crisis Removal Notification,
Notice of Investigation Findings and Discipline, Confidential Request for
Appeal, Complex Area Superintendent's Appeal Decision, and the critical
Manifestation Determination Review.
On a personal note, I feel that Principal Dickerson's failure to implement
Chapter 19 procedures unnecessarily endangered the safety of the children
under her care, and allowed their victimization.
We will never know how much of that victimization could have been
prevented, or would never have occurred, had Principal Dickerson followed
the rules she pledged as an administrator, to uphold.
I ~ ''
SOH 23
s 7899
Summary Notes on the Misconduct of Principal, Hawaii School for the Deaf and the Blind
NOTE:
1. There are twelve (12) incidents that were relayed from Roxsanne Tomita, a privately contracted service provider for the HSDB to Alan
Shimabukuro, Department Educational Specialist, who conducted an interview during Ll-ie initial stages of the administrative inveStiga.tion.
These reports include twelve different victims that were allegedly violated on multiple occasions dating back to 2004, and involved five
(5) different alleged suspects assaulting more than one victim over the same period.
2. There are another twenty (20) more alleged vscti.'DS that were brought to Alan Shimabukuro attention, but was unable to elaborate
before ruming the investigation over to the appointed Lead Investigator.
3. The information provided in the table represents:
a. Column 1 - Action~ prescribed for school administrators or designees that are outlined in Chapter l 9 related to serious
discipline and/or crisis removal
"'0
(/)
-....J
IV
.:.
b. Column 2 - Summary of review, conducted by Caivin Nomiyam a. Complex Area Superintendent, of the student profiles in
eCSSS .in which students have been identified as alleged suspects. or alleged victims, and were enrolled in BSDB in School
Year 2010-2011.
(0
0
0
c. Column 3 - References to Chapter 19. Sub-Chapters, and paragraphs that apply to the actions prescribed for school
::iclministrntors or clcsignees .
d. Column 4 - Actions the Principal failed to perform as prescribed in Chapter 19
SITUATION:
An incident involving a Chapter 19 offense lms been committed. The diagram below outlines
decision points aod actions a school administrator must take t<J bring the matter to a close.
Preliminary Inquiry/Findings (Yes/No)
Chap 19 Violation (Yes/No)
Investigation
1. Determined Crisis Removal or suspension is in order
2. Inform parents
3. Conduc t and comlete iuvcstigation
4. Decisio n to impose serious disci pline
5. W itten report (cCSSS form)
a. Summary of testimony of witnesses i nLerviewed
SOH 25
s 7901
Possible consequence.> when School Administrntors fail to adh ere to the pro vis ion set forth in
Chapter 19 with regards to serious di sc ipline:
I. Fail
w-
SOH 26
s 7902
I/Ell A9ERCROMB IE
GOVERNOR
KATHRYN S MAlllYOSHI
!iUP S ~tEJia!/JT
STATE OF HAWAII
DEPARTMENT OF EDUCATION
Calvin Nomiyuma
Complex Area Superintendent
Farrington, Kaiser, Kalani Complexes
s 7903
atl~c~ed
n ...UVVtuHAHT
Deputy Superintendent
July 2004
CHAPTER 19
Class A and B Hearings
SERIOUS
DISCIPLINE
POSSESSlON OF
FIREARM
19A
Confidential Olsciplinary Notice
Signed by the Principal and sent to the
ParenVG1Jardlim.
198
Confldontlal lnyestlgatlon Report/Notice
'
I
19C
Confidential Serious Dlsclplfne Notice
Submitted with 198 and sent lo the GAS for
approval and signa ture.
.'
Cl:!ANG ES I~ PROCOURE
Sah ooi/CAS will send all Records, Evidenoi'!, Pleadings to th13 Superintendent's Office .
See Checklist and Directions.
Deputy Superintendent will examine th e Evidenoe and render a Decision on the Dlsciplinary Action.
Parent/Guardian may file an Exception to the Decision and presen t arguments .
Deputy Superintendent will schedule this meeting .
Attachment A
SOH 28
s 7904
GENERAL SITUATION:
An incident involving a Chapter 19 offense has been committed. The outline below describes
decision points and actions a school administrator must take to b1ing the matter to a close.
Preliminary Inquiry/Findings (Yes/No)
Investigation
l. Determined Crisis Removal or SL1spension is in order
2. Inform parefltS
3. Conduct and complete investigation
4. Decision to impose serious discipline
5. Written repoti (eCSSS form)
a. Swnmary of testimony of witnesses interviewed
b. Reason for initiating of disciplinary proceedings
6. Give parent notice of findings (<'CSSS form)
7. Studenl or parent given opportunity to present student's version
SusP.ension (no Crisis Removal)
1. Conduct, complete investigation with findings
2. Findings sustained = suspeflsion
a. Parents allowed being present when student is unable to understand process
3. Suspension totaling 10 or more days in one semester, apply due process (eCSSS form)
4. Verbal notification of suspension to rarents, rega1 dless number of days
S. Mail/deliver notice of suspension to parents upon com;Jletion of investigation
6. Copy of Notice to CAS
7. Attempt confirmation with parent
Due Process (for serious discipline, other than Crisis Removal)
1 Notify CAS to initiate disciplinary proceedings by .obtaining verbal authorization from CAS
2. Inform the parent
3. Mail to parent written notice of serious within three days of verbal approval from CAS,
discipline incident with appeal form (cCSSS form)
4. Implement due process when requested.
Attachment B
SOH 29
s 7905
Summary Notes on the Misconduct of Principal, Hawaii School for the Deaf and the Blind
Evidence
- - - -----i-- - - - - - - - - -- ----1l_____R_c_f_er_e_n_c_e _
"'
0
:I:
(J)
"'0
-.J
CD
..
Con~.q~ence
I
o
otfensc.
I
I
0)
1 "
Cl
Attachment C
Summary Notes on the Misconduct of Principal, Hawaii School for the Deaf and the Blind
NOTE:
1. There arc twdve ( 12) incidents that were relayed from Roxsaru1e Tomita, a privately contracted service provider for the HSDB to Alan
Shimabukuro, Department Educational Specialist, who conducted an interview during the initial stages of the administrative investigation.
These reporlS include twelve differenl victims that were allegedly violated on multiple occasions dating back to 2004. and involved five
(5) differc=nt alleged suspects assaulting more than one victim over the same period.
2. There are another twenty (20) more alleged victims that were brought to Alan Shimabukuro attention, but was unable to elaborate
before turning the investigation over to the appointed Lead Investigator.
VI
(/)
-.J
co
0
-.J
0
:r
~
a. Column 1 - Actions prescribed. for school administrators or designees that are outlined in Chapter 19 related to serious
discipline and/or crisis removal
b. Column 2 - Summary of review, conducted by Calvin Nomiyama, Complex Arca Superintendent, of the student profiles in
eCSSS in which students have been identified as alleged suspects. or alleged victims, and were enrolled in HSDB in School
Year2010-20ll .
c.
Column 3 - References to Chapter 19. Sub-Chapters, and paragraphs that apply to the actions prescribed for school
administrators or designees.
Attachment C
SOH 32
s 7908
2
out, and the media could destroy us if this leaks out."
Mr. Nomiyama immediately picked up the phone and called Principal
Dickerson. I heard him ask her what was go ing on. The conversation was
short. I'm not sure what Principal Dickerson told him, because Mr.
Nomiyama did not seem upset.
Throughout that next week, I continued to consult with Principal
Dickerson, and to make sure all Special Education procedures were
followed, such as providing mental health support and counsel ing for HSDB
students, and making sure that each student's Individual Education Plan met
the student's needs .
My area of responsibility is limited to Special Education issues, however
in this case the Chapter 19 process needed to be completed in order for the
Manifestation of Determination Review to be completed. This review
involves a team of individuals knowledgeable about the student, trying to
detennine whether "The conduct in question was caused by, or had a direct
and substantial relationship to thestudenes disability."
In the case o~ my concern was that Principal Dickerson's
investigation was not completed in a timely manner. Between April 14[\
201 1 and May 31 si, 20l1, [ asked Principal Dickerson several times if she
had completed her investigation. She told me each time that she was
"working on it." Again, my responsibility involved the ultimate completion
of the Manifestation of Determination Review, which related t~
disability. But in order to complete that rev iew, other procedures
covered by Chapter 19 needed to be met, sucb as an investigation and
disciplinary action against the alleged perpetrator.
According to my search of the DOE's ECSSS, our electronic database,
Principal Dickerson's investigation was not recorded until May 31 5 \ 20 l I.
There are no database entries indicating any disciplinary action against
student(
was ever imposed prior to May 31 9 \ 2011. or that a
Manifestation of Deterntination Rev~ed.
Pl
6/ I I
SOH 33
s 7909
Jj
SOH 34
s 7910
April 16, 2009, he had been forced to orally copulate five boys for the past
two to three years .
Immediately after ,
told me this, I reported what he told me to
Sydney, and I gave her the names of the five boys identified by ~
Again, I believed she would follow up. I said, "You're going to contact the
parents, right?" She indicated she would, but to my knowledge, she never
did .
On April 29, 2009, the police came to the school, but would not make a
report. $
0 mother filed a complaint with the Department of
Education. Sydney asked me to write about what I knew about
case for the DOE, which I did.
In May 2009, Scott O'Neal and I put a group together of the boys who
I as sexual offenders. At our first meeting, these
w ere identi fied by J
boys disclosed names of students who had forced them to have sex, and in
tum, what students they forced to have sex. I was both appalled and
overwhelmed by what the boys told me. Right after that meeting I went to
Sydney 's office with Scott. Sydney, Scott, myself and the two counselors
who were there, agreed to divide up the list of students identified as
involved, and each of us would conduct interviews with the students to
determine the extent of the problem. Sydney said she would call the
parents.
I interviewed two or three students. They denied any knowledge of being
victimized. I reported this to Sydney. 1 had also called the parents of the
students I had interviewed, as a mandated reporter.
On April 14, 2011,
disclosed to me that she had been
on four separate occasions
sexually assaulted by student I g
between January and April of this year, on the school bus .
dtold me this, I reported it to Sydney. She said,
Immediately after l
"What are you going to do?" I said, "Call the parents, and then call the
police. She sai~ "Don't call the police." I said, "How about if I call the
parents and they're willing to file charges?" She said, "O.K." I called the
parents and the police . There were three witnesses to a videot
j
l had
made of the latest assault of - Those three said they had also been
victimized by I & I
I have made several statements to the police about this entire affair.
My biggest concern about Sydney's role in all of this is that she did not
appreciate the seriousness of the problem when it was first brought to her
SOH 35
s 7911
SOH 36
s 7912
or4m1~
\\That I do recall on April 16, 2009, was that Roxsanne and Student
now confirmed
Services Coordinator Steve Laracuente told me that
that he had been the victim of sex assault, and had provided them with the
names of the five boys he had been forced to have sex with. As I said
SOH 37
s 7913
earlier, IT
had denied to me he had been forced to have sex. I don't
recall any agreement between myself and the counselors to interview those
. During this time, my mother had been hospitalized, and
named by b
so my recollection may not have been entirely clear. She passed away on
April 22, 2009.
& school counselor Harry Hayler
With this new infonnation byl
called the police on April 29, 2009. The police came, and declined to make
a criminal case. I recall they said they couldn't prove coercion.
In hindsight, I again failed to meet my responsibilities under Chapter 19,
by not reportinJI
f allegations. They should have been investigated
and entered into the ECSSS electronic data system.
I did not ask Roxsanne to respond to a complaint to the DOE by
mother. I drafted the response.
I do not recall school nurse Maureen Lee ever telling me in 2008 or 2009,
or any other time, that studentf?
forced student
to perform oral sex on him.
I also do not recall on April 29, 2009, Dr. Kimo Chan, our school
contracted psychiatrist, ever warning me to resolve the sex assault cases or
the school would risk being shut down. Again, this was during the time my
mother had just passed away.
I am aware questions have arisen regarding student sleepovers at Scott
O'Neal 's house. I know of nothing inappropriate ever having occurred, and
the sleepovers required parental pennission. These were done for school or
extra-curricular activities, such as Special Olympics or other community
events.
On April 14, 2011, Roxsanne told me student
had
sexually assaulted student
on the school bus, and that
Roxsanne was going to call the police. I told her to call
mother
also. The police came to the school and I
I was arrested.
Although in the chronology I have given investigator Matt Levi I wrote
that I contacted CAS Nomiyama about the
JS arrest, I am now not sure
ifI contacted him or he contacted me, and whether it was on April 14th or
15 1h. I have no documentation regarding that contact.
In the f P case, I again failed to meet the Chapter 19 reporting
requirements, including failing to investigate the case and entering the
information into the DOE electronic database.
I recall CAS Norniyama reminding me at least twice between mid-April,
SOH 38
s 7914
3
2011, and mid-M ay, 2011, to enter the
case in the DOE electronic
database. Despite his reminders, I didn't do it. I didn't do it because I
didn't know how, electronically. I finally entered it May 31st, 2011, six
weeks after the
arrest. I should have asked CAS Nomiyama for
help, or let him know it hadn't been entered.
I also reme~nber Mavis Kawamura telling me t h e - case needed to be
entered into ECSSS, but I still didn't do it until May 31 5 \ 2011.
I can honestly say I was unaware of the Chapter 19 reporting requirements
until after the
arrest on April 14, 2011. I was also not
aware until then that there was a 5-day reporting requirement, or that cases
such as his needed to be investigated irrunediately.
With all my responsibilities at HSDB, including the budget, facilities, the
boarding program, transportation of kids from the neighbor islands, hosting
a national conference of administrators, and providing technical and other
assistance to schools with deaf students, learning Chapter 19 was not a
front-burner issue.
g/1s /11
SOH 39
s 7915
My name is Scott O'Neal. From 1998 until August of this year I was a
contract therapist at the Hawaii School for the Deaf and the Blind, as well as
other schools throughout the state.
HSDB student
was a client of mine by way of DOE
referral. He was my client from 2006 until 2011.
Since
first became my client, it became increasingly clear to me
that he needed additional treatment specific to his sexually abusive
behaviors, and that those services may have been beyond the capabilities of
HSDB to provide. In 2009, after
was accused of forcing student
to perform oral sex on
) in the dorm, J
recorrunended to Principal Sydney Dickerson that at a minimum
needed a psychosexual evaluation to determine and make recommendations
as to his suitability to remain in the school dorm. It was also my
recommendation that without evaluation,
should not be allowed to
return to the donn. was suspended for a short time from school,
but a psychosexual evaluation was not done, because his parents did not
allow it.
was not allowed to return to the dorm, but he did come
back to school.
While f felt then and feel now that he shou ld not ha ve been allowed back
in school by Sydney tmless additional safeguards were put in place, to my
understanding there was no other option for school placement for him .
When
came back from suspension, some changes were made by
Sydney, such as additiona l locks and close supervision. At the time I
thought these changes were s ufficient because there had been no reports of
misconduct by to me.
. . . . and
were also clients of mine .
Even though I have never had substantive training on Chapter 19
procedures, any offense I felt fell within Chapter l 9's reporting
requirements I reported to Principal Dickerson. I assumed she followed her
SOH 40
s 7916
SOH 41
s 7917
My name is Maureen Lee. I am the school nurse at the Hawaii School for
the Deaf and Blind. I am a Department of Education employee.
Sometime in 2008 or 2009, I attended a meeting with our psychiatrist Dr.
Kimo Chan and student
,
Counselor Inga Okuna-Park
was also at the meeting, acting as interpreter.
In that meeting, b
first denied then admitted that s t u d e n t had forced him to perfonn oral se~ on in the first floor
laundry room ofF Building, on campus . . . said that-and he
were over in the laundry room, and P
3 1 ropped his pants and pushed
P head down to 3
I groin, and made him perform oral sex.
I felt so bad to hear that, it
like a lost childhood f o r - . having to
go through that.
When Dr. Chan asked 7 S how he felt when ..... did that, said that it was wrong for
to do it.
After the meeting, I went right to Principal Sydney Dickerson's office to
report what I had just heard. Sydney was in her office and I told her what
thad said. I expected her to be concerned. Instead, she acted like I
was bothering her. She just picked up her cell phone and started texting.
She didn't say anything. Then she put her phone down and said, "O.K.,
that's done." She said, "I just texted Bobbie to tell her to make sure the
kids aren't unaccompanied to the laundry room." Bobbie is the head
houseparent. Then I asked Sydney, "are we going to report this to the
parents or anybody else?" She just said; "I'll take care of it.'' She said it in
a tone of voice that said to me that the conversation was over. I left her
office right after that.
I do not believe-primary caregiver, his grandmother, was ever
contacted by Sydney. In May of this year, therapist Roxsanne Tomita told
me she talked to-grandmother, who told Roxsanne that no oi:i-e over
called her about the incident.
was
! P-1/
SOH 42
s 7918
My name is Inga Park Okuna. I worked at the Hawaii School for the Deaf and Blind from 2001 until 2009. I was first a
teacher, then a counselor .
Now that incidents of improper sexual activity at HSDB have become public, I am learning that Principal Sydney
Dickerson did not take action when she should have. I thought she had taken care of things and fulfilled her
responsibilities as an administrator.
In 2009, we became award that student
a result of that incident, we learned that a number of other boys and girl(s) may have been sex assault victims. We also
then believed the problem of improper sexual activity may have been larger than we thought. After the incident, I was
surprised and disappointed that
the boy named by. . . as the primary perpetrator, was not removed
from the campus. This would have been Sydney's decision. I also know of no significant treatment any of those involved
received.
In 2006, I believe, I called Child Protective Services, because student
sexual position in the dormitory. We called the parents and had a meeting at the school. I remember Sydney telling
and his parents, "If anything like this happens again, you will be kicked out of the dorm and will have to stay
with a relative on the island "
After this, I heard of more questionable stories about
still in the dorm, after what Sydney had said in the earlier meeting.
I do not remember interpreting at a meeting with in which he said he had engaged in oral sex with another
student, and I believe Nurse Lee is mistaken if she remembers me there.
My biggest problem with all of these things that went on is that later incidents could have been prevented if Sydney had
taken action earlier, Thi5 would include the following: Chapter 19 procedures, better staff training, more security
guidelines and follow-up to make sure procedures were being followed.
I consider Sydney to be dishonest. I have seen her lie. I also believe she intentionally failed to report some of these
incidents of sexual misconduct to the DOE or police because in her mind, she didn't want the infractions to become
public and make her look' bad. I also do not believe her first interest is the welfare of the students. I base that on
personal contact with her and seeing how she ran the school. I will never forget one comment she made to me about a
student she didn't like. She said, "I want to hire a hitman to knock him off." She may have been joking but she should
never have said something like that . I am also submitting to investigator Matt Levi, an e-mail from Sydney in 2007,
about how she handled a group of students who hac.J been caught with chewing tobacco. I think her actions and tone
show how mean-spirited she is.
Signc1ture
_L.272
'tf~ <if},,._/.,/ a~
Date/Time
-----''8_-_2-_'1_ -_ _/_._/_-r/_IO
_.-_.'~
_~_a_._a_L,_
.
Print nCJm e
SOH 43
s 7919
Sydney
Dickerson/HCOB/f II DOE
09/26/2007 10:30 AM
I have to admit, I enjoyed it! For those of you in the know, there was a group of 5 students that snuck into
the bathroom on Monday and took a try of chewing tobacco. All did not feel well , some to the point of
throwing up! Some staff seemed to think it was food poisoning, but no, it was stupidity I
Some of the te achers spent cla ss time yesterday going over what happens to people that 'chew tobacco
with some really graphic picturo=s To those of you thank you! I think my being off campus and having
them stew about it for a day made it e;en better
This morning I met with the five students (all high schoolers) and had \hem sit there and sniff a few
ounces of tob<occo for quite a long time Amazingly they didn't think to breathe through their mouths
Anyway, I have never seen such shades of green on children's faces! Their eyes watered and it W3s ha'd
for me to con lain my laughter
Their consequences will be the t they Viii/ be cleaning the bathrooms (since they puked in them) everyd3/
until the break The/ will do this before they get to eat lunch. Their 4th period teachers, cafet eria 2nd
custodians have the s '~h9dul9
At the encl of it all, 1 had them take a good long whiff again Probably 3-4 minutes before sending them to
class Some of the homeroom teachers may have noticed they didn't look so good!
I have to admit, I enjoyed it!
Sydney
SOH 44
s 7920
SOH 45
s 7921
2
investigation of
claims, but T don't believe there was . After
bringing
to Sydney, I thought to myself, " Oh no, there goes
a g ain." It was then that I believed
should be
pemrnnently removed from the school.
Sometime, I believe in the fall of 2009 or the fall of 2010, I heard that
~ad perfonned oral sex on I' g
on the school bus
during a bowling outing after school. I spoke to the driver of the bus, Steve
Hanai, who is also the coach of our bowling team. He confirmed to me that
another student on the bus to1d him that the sexual act had taken place while
Steve was drivin~ . It is my undei:standing that the incident was reported to
Sydney, but again, no investigation pr acti on was ever taken that I'm aware
~
of.
'
,
orl
~f-P-9~~-.::::::
. -~~M~-~-"l..&-
., .t.
\
--;
. .'
_()_gh-3/a
I
SOH 46
s 7922
SOH 47
s 7923
111
SOH 48
s 7924
and I were on duty. When the police came they told us that if it was a fight
someone would be arrested, but if it was an argument, there would be no
arrests. Daniel texted Sydney and told her about the fight, but she texted
back and told us to tell the police it was just an argument and not a fight. In
my mind, then and now, there was no question that Sydney wanted us to lie
to the police about what happened. We lied to them and said it was an
argument, because we were afraid of Sydney. If you worked here, you had
to do what she said. Her word was the law.
I never had any real training in Chapter 19 before this year, and ifl had
known then what was in it, there is no question that we could have made
some positive changes. I definitely do not want Sydney back as
Ad.mi nistrator. A lot of good people left here because of her.
As far as
I L is concerned, her not kicking him out allowed him to
re-offend.
Sydney wanted to be known as a good administrator. She hid things so
that her career and her image wouldn't be damaged.
4:tg
P.l~-
SOH 49
s 7925
SOH 50
s 7926
the police, because it was clearly a fight, and I had explained that to her.
I didn't speak to the officers who arrived because I'm deaf. Jay first
started to tell the police it was a fight, but then spoke to Sydney by cell
and ended up telling the officers that
?nd
had just gotten into
an argument.
After the police left, I was upset. I told Bobbie about how Sydney had
told us to change our story for the police, and Bobbie just said "Sydney is
the one who makes the decisions."
I think
and . . .h hould have had consequences for their fighting,
but I don't think anything was done.
I don't want Sydney Dickerson back. J have no trust in her at all. There
were other situations she could have resolved but she didn't.
After that incident with and- . there were other times l could
have called the police because of things happening in the boys' dorm, but I
didn't because I didn't think anything would get done .
.iL~f'-cJr- _
_
I Q! _L,,+ ;;,
_ o_,_/_..__
I ___
SOH 51
s 7927
Statement of Charlie Lu
/O 16 I .101/
- Jo :o/
SOH 52
s 7928
AM
SOH 53
s 7929
I went to her because I feared for the safety of our students, both physically
and emotionally, and I kept hearing more and more stories about improper
sexual activity and bullying on campus. I was also concerned that parents
may not have been aware of some of the things that were taking place, or
that the kids were not telling them what was going on, maybe because of an
inability to express themselves fully to their parents.
J asked Sydney directly, "Are you aware of all these stories about sexual
activity on campus, and bullying and fighting in the dorms?" Sydney
answered, "Yes," but she had this look on her face like she was aggravated
that I had asked her. She said, "We're taking care of this, but it doesn't fall
under your job description.''
Her telling me that made me feel that I couldn't do anything for the kids at
our school, or their parents.
After that conversation with Sydney, l also felt I could no longer continue
to go to her with issues, and I never did.
SOH 54
s 7930
SOH 55
s 7931
CERTIFICATE OF SERVICE
Plaintiffs,
VS,
CERTIFICATE OF SERVICE
I I{EREBY CERTIFY that I caused a true and correct copy of the foregoing
document to be served on the following persons by facsimile, hand-delivery or U.S. mail,
postage prepaid (as indicated below) to their respective addresses:
H,dND.
DELIVER.ED
DOUGLAS S. CHIN
Attomey General of Hawaii
ROBIN M. KISHI, ESQ.
KATHY K. HIGHAM, ESQ.
CARON M. INAGAKI, ESQ.
Deputy Attorneys General
Department of the Attorney General
State of Hawaii
425 Queen Street
Honolulu, Hawai'i 96813
Attorneys for Defendants
-l
EMATI,
MAILED
HANDDELIVERED
Judge Eden Elizabeth
Hifo
PAUL
TON
ERIC G.
GLENN T. MELCHINGER
SUSAN DORSEY
Attorneys for Plaintiffs
962660v1/11047
-l
MAILED